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Comment 12 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJim
Last NameMeyer
SubjectCARB and EJ - Where did Science go?

In the past, we have been able to depend on the California air regulators for taking science based, data driven approaches to solve problems. This ATCM proposal is evidence that science and data are trumped by politics.

According to the SCAQMD MATES V study, there are over 300 pounds of hex chrome emitted annually in the region. Note, that is only in the South Coast area, not the entire state. Let’s call it 500 pounds in the state.

According to the CARB ISOR, SRIA, and Appendix B of this ATCM, the amount of PERMITTED Hex Chromium emissions by chrome platers in THE ENTIRE STATE is 10.19 pounds.

According to the CARB Appendix B of this ATCM, the ACTUAL Hex Chromium Emissions by chrome platers in the ENTIRE STATE are 0.901 pounds.

So, this proposed rule bans decorative platers in the short term, and functional platers in the long term to save less than 0.2% of the hexavalent chromium emissions in the state. That is one pound out of 500.

CARB presents the purpose for the rule change as being necessary to achieve environmental justice goals. (See the purpose section of the ISOR pages 1 to 5).  But, based on data, this doesn’t even seem to be valid. You can see for yourself if you take the time to read the AB 617 process Community Emissions Reduction Plans from the following environmental justice communities: 1) Wilmington, Carson, and West Long Beach; 2) San Bernardino / Muscoy; 3) East LA, Boyle Heights; 4) East Coachella; 5) South LA; and 6) Southeast LA.  All of those community generated plans (with one exception) appropriately recognize that chrome plating firms are not an area of concern. So, who is CARB listening to?

Why would CARB move to implement a STATEWIDE ban based on what might be an issue in one EJ community? Keeping in mind that metal working is a major job engine for California, is this how social justice is supposed to work. Do jobs count for anything?

It seems to me that the whole point of the EJ movement is to be responsive to people in their communities. So, to do that, the state (CARB) should not implement statewide edicts that impact communities other than the ones where problems may exist. Otherwise, they create more problems than they solve! Things just get worse in more communities.

It is a fact that stainless steel contains chromium. According to CARB and AQMD and science, the heating, forging, grinding, milling, melting, welding, and cutting of stainless steel releases hexavalent chromium. It isn’t just chrome plating. So, is this rule-making a shot across the bow to the entire metal working industry in California? Should we all just leave now? After all, the metal finishers were told repeatedly that since there is no “safe” level for hexavalent chromium it was necessary for CARB staff to propose this complete ban based on California health and safety laws. They say they have no choice. If that is the case, then machinists, welders, recyclers, fabricators, heat-treaters and all other metal workers will soon join the chrome platers in the unemployment line.

According to the American Cancer Society, hexavalent chrome causes cancer. Somehow, the California Health and Safety Code and therefore CARB bans it.

But, also according to the American Cancer Society, alcoholic beverages (wine) cause cancer. California markets it to the world and our governor owns a wine business. I call bullstuff on the lie that CARB is forced to impose a ban. 

There are serious problems at CARB. They are being pulled away from data and science. It is hurting the state. High-paying, middle-class jobs are leaving. As CARB focuses on satisfying squeaky wheels it loses credibility on this and other important work. The job of a regulator is to adopt thoughtful rules, a ban is not thoughtful. CARB should adopt an emissions based approach.

Original File Name
Date and Time Comment Was Submitted 2022-12-13 12:22:57

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